https://www.taxtmi.com/caselaws?id=467495 Corporate guarantees are treatable as international transactions for transfer pricing and their arm's length charge may be estimated by the interest-savings approach with apportionment between guarantor and borrower; on facts the tribunal reduced the commission rates to 0.625% and 0.75% for two bank transactions. For disallowance under Rule 8D(2)/section 14A the ICDS measurement (cost/acquisition basis where ICDS applies) prevails over Ind-AS fair-value accounting; the issue is remitted to the assessing officer for factual verification and recomputation using audited cost figures. en-us Mon, 13 Oct 2025 00:00:00 +0530 Fri, 20 Mar 2026 18:58:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467495 Corporate guarantees are treatable as international transactions for transfer pricing and their arm's length charge may be estimated by the interest-savings approach with apportionment between guarantor and borrower; on facts the tribunal reduced the commission rates to 0.625% and 0.75% for two bank transactions. For disallowance under Rule 8D(2)/section 14A the ICDS measurement (cost/acquisition basis where ICDS applies) prevails over Ind-AS fair-value accounting; the issue is remitted to the assessing officer for factual verification and recomputation using audited cost figures. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467495